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### DOCKET NO: A-98-49

Item: II-B3-111



## 2009 - Monitoring Inspection Report

INSPECTION No. EPA-WIPP-7.09-14b

OF THE

WASTE ISOLATION PILOT PLANT July 14 to July 16, 2009

U. S. ENVIRONMENTAL PROTECTION AGENCY

Office of Radiation and Indoor Air Center for Waste Management and Federal Regulation 1200 Pennsylvania Avenue, NW Washington, DC 20460

September 20092 Table of Contents

1.0 Executive Summary...................................................................................................................3

2.0 Scope..........................................................................................................................................3

3.0 Inspection Team, Observ ers, and Participants...........................................................................4

4.0 Performance of the Inspection ...................................................................................................5

4.1 Monitoring of Geomechanical Parameters .............................................................................5

4.2 Monitoring of Hydrological Parameters .................................................................................7

4.3 Monitoring of Waste Activity Parameters ..............................................................................7

4.4 Monitoring of Drilling Related Parameters ............................................................................8

4.5 Monitoring of Subsidence Parameters....................................................................................9

5.0 Summary of Findings.................................................................................................................9

Tables

Table 1 Monitored Parameters

Table 2 Geomechanical Parameter and Values Measured to Confirm Them

Attachments

Attachment A Inspection Plan and Checklist

Attachment B Documents ReviewedPage 3 of 17 1.0 Executive Summary

The U.S. Environmental Protection Agen cy (EPA) conducted an inspection of the Department of Energy’s (DOE) Waste Isolation Pilot Plant (WIPP) from July 14 to July 16, 2009, as part of our continuing WI PP oversight program. The purpose of this inspection was to verify that DOE continues to adequately mon itor ten parameters listed in the Compliance Certification Application (CCA), Volume 1, Sect ion 7.0, in particular Table 7-7 (See Table 1, COB-M2009-1). Attachment A contains the in spection plan and the checklist used by the EPA inspector, and Attachment B lists documents reviewed by the EPA.

The inspection examined the implementa tion of monitoring for geomechanical, hydrological, waste activit y, drilling related, and subsidence parameters. The EPA inspectors toured locations where measurements are taken, reviewed parameter databases, and reviewed documents and procedures direct ing these monitoring activities.

EPA found that DOE has effectively impleme nted the monitoring programs at WIPP for

all areas reviewed. EPA did not have any findings or concerns. The inspectors also confirmed

that the results of DOE monitoring programs are reported annually.

2.0 Scope

The EPA WIPP Compliance Criteria (40 CFR Part 194.42(a)) require DOE to “conduct an analysis of the effects of disposal system parameters on the containment of waste in the disposal system.” The results of these analyses were included in the 1996 Compliance Certification Application (CCA), confirmed in the 2004 Compliance Recert ification Application (CRA), and were used to develop pre-clos ure and post-closure monitoring requirements.

Volume 1, Section 7.0, of the CCA documented DOE’s analysis of monitoring parameters. Table 7-7 of the CCA lists the ten parameters that DOE determined may affect the disposal system. These parameters are grouped in to major categories and listed in Table 1. EPA accepted these ten monitoring parameters in the 1998 Certification Decision and confirmed them

in the 2006 Recertification Decision.Page 4 of 17 Table 1 - Monitored Parameters

Geomechanical Parameters

- Waste Activity Parameter

- -Creep closure, -Waste Activity -Extent of deformation, -Initiation of brittle deformation, and Subsidence Parameter

- -Displacement of deformation feat ures. -Subsidence measurements

Hydrological Parameters

- Drilling Related Parameters

- -Culebra groundwate r composition and -Drilling rate and -Change in Culebra groundwater flow -The probability of encountering a

direction. Castile brine reservoir.

This inspection was performed under author ity of 40 CFR 194.21, which authorizes EPA to verify the continued effectiveness of the pa rameter monitoring program at WIPP. Inspection

activities included an examination of monitori ng and sampling equipment both on and off site, and in the underground. EPA also reviewed numerous sampling procedures and measurement techniques and verified impleme ntation of an effective qual ity assurance program (see the document list in Attachment B of this report).

3.0 Inspection Team, Observers, and Participants

The inspection team consisted of four EPA st aff. Thomas Kesterson of the State of New Mexico Environmental Depart ment observed the inspection.

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA

Nick Stone Inspector EPA

Tom Peake Inspector EPA

Jonathan Walsh Inspector EPAPage 5 of 17 Numerous DOE staff and contractors participated in the inspection; below is a partial list.

DOE/Contractor Participants

Dan Ferguson Dave Speed

Joel Siegel Dave Kump

Rey Carrasco Stan Patchet

John VandeKraats Art Chavez

David Hughes Mansour Akbarzadeh

Larry Madl Ben Zimmerly

4.0 Performance of the Inspection

The inspection began on Tuesday, July 14, 2009, with an opening meeting (COB-A2009- S1a, -S1b) where changes in the parameter m onitoring programs since the previous inspection were discussed by site staff (COB-M2009-I1 to –I10). On July 15, 2009, the inspection

continued with interviews and demonstrations of various aspects of each parameter monitoring area. On July 16, 2009, EPA inspectors examined the database(s) used to store Delaware Basin parameters and the WIPP Waste Information Syst em (WWIS) waste computer database system. The underground, where geomechanical measurements are taken, was also inspected on July 15, 2009. The inspection closeout meeting was he ld on July 16, 2009, in Carlsbad New Mexico (Sign-in sheet COB-A2009-S1a).

The Agency reviewed three fundamental areas to verify continued implementation of the DOE parameter monitoring program during the pr e-closure phase: 1) written plans and procedures, 2) quality assuran ce procedures and records, and 3) results of the monitoring program in the form of raw data, intermediate re ports, and final annual reports, if appropriate. The inspection checklist in Attachment A provi des details of these inspection activities.

EPA also reviewed various activities to veri fy effective procedure implementation. The inspector observed a demonstrat ion of the WWIS and reviewed the Delaware Basin Drilling Surveillance Program, Groundwater Monitoring Program, and the Geomechanical Monitoring Program.

4.1 Monitoring of Geomechanical Parameters

DOE committed to measure four geomechani cal parameters in the CCA: creep closure, extent of deformation, initiation of brittle deform ation, and displacement of deformation featuresPage 6 of 17 (Table 2). WIPP has four programs that supply information for these four parameters: the geomechanical monitoring program, the geoscien ces program, the ground control program, and the rock mechanics program. These programs are documented in the WIPP Geotechnical Engineering Program Plan, WP 07-01 (COB-M2009-E). The results of the geotechnical program are reported in the Geotechnical Analysis Report for July 2007 - June 2008, DOE/WIPP-09- 3177, Volumes 1 and 2 (COB-M2009-A1 and -A2).

Table 2 - Geomechanical Parameter a nd Values Measured to Confirm Them

Monitor Parameters Confirmed by Measuring Related Procedure(s) creep closure and stresses conver gence measurements WP 07-EU1301

borehole extensometers WP 07-EU1303

WP 07-EU1304

WP 07-EU1308

extent of deformation borehole extensometers WP 07-EU1301

borehole observations WP 07-EU1303

WP 07-EU1305

WP 07-EU1308

initiation of brittle fracture mapping WP 07-EU1301

deformation borehole observation WP 07-EU1303

WP 07-EU1001

displacement of deformation ge ologic mapping WP 07-EU1301 features comparison WP 07-EU1303

WP 07-EU1001 -From DOE/WIPP 09-3177 (COB-M2008-A1), Volume 1, Section 1.4

Geomechanical staff manually measured c onvergence values in the underground (Figure 1, Horizontal Convergence Measurement) and the inspector examined the results documented in field data forms. After taking the measurements the inspector observed staff inputting these data into the computer database (COB -M2009-S42 to S47). The inspector found that procedures arePage 7 of 17 adequate for proper measurements; procedures are implemented adequately; documents and field data forms are controlled; and data is adequately checked, using check prints when necessary, to assure adequate quality.

4.2 Monitoring of Hydrological Parameters

DOE committed to measure two hydrologi cal parameters in the CCA: Culebra groundwater composition and changes in the Culebra groundwater flow direction. Related parameters are measured and documented in the WIPP environmental monitoring program. These programs are documented in the WIPP Gr oundwater Monitoring Program Plan, WP 02-1 (COB-M2009-C). Results of this program are pub lished in the WIPP Site Environmental Report for 2007, DOE/WIPP 08-2225 (COB-A2009-C). This document describes the groundwater monitoring program and reports re sults for the previous year.

During the 2009 inspection, the EPA inspecto r requested information about changes in the program since last year. The opening meeti ng presentation noted that one new Culebra well was drilled, the H-4BR well to replace H4B (COB-M2009-I3). The current well monitoring network consists of 47 Culebra, 11 Magenta, three dual Culebra/Magenta completions, one Dewey Lake, two Bell Canyon, and 20 shallow Sa nta Rosa/Dewey Lake wells. Besides examining the Site Environmental Report for 2007, the inspector examined flow direction maps, well location maps, water level measurements, a nd water chemistry data (COB-M2009-S12 and - S15). DOE and Sandia National Laboratory (SNL) implemented a new procedure to produce the potentiometric map used to estimate flow direc tion for the monitor require ments. The procedure is called “Preparation of Culebra Potentiome tric Surface Contour Maps” (SP 9-9, COB-M2009- S12). SNL present a presentation that descri bed the use of this new procedure (COB-M2009- S15). The inspector examined this new approach and found it to be adequate for this monitoring requirement. The inspector found the hydrologic al monitoring program to be improving and adequate.

4.3 Monitoring of Waste Activity Parameters

DOE committed to monitor the activity of wa ste emplaced in the CCA. This parameter is part of the extensive database collected for each container shipped to WIPP and is stored in the WIPP Waste Information System (WWIS). The WWIS is a software system that screens waste container data and provides reports on the Tr ansuranic (TRU) waste sent to WIPP. The requirements for the WWIS are discussed in th e WIPP Waste Information System Program and System Data Management Plan, WP 08-NT.01 (C OB-M2009-H2). DOE yearly reports waste activity information in the Annual Change Report, Table 3 (DOE/WIPP 08-3317; COB-M2009- P).

WWIS staff demonstrated that the WWIS can receive data and that the WWIS can generate needed reports. The inspector obtained copies of the Nuclide Report (COB-M2009-Page 8 of 17 W1) and WWIS Waste Container Data Reports (COB-M2009-W2, -W3, and -W4). The inspector verified that DOE tracks and a nnually reports the waste activity at WIPP.

4.4 Monitoring of Drilling Related Parameters

DOE committed to measure two drilling relate d parameters in the CCA: the drilling rate and the probability of encounteri ng a Castile brine reservoir. Th ese parameters are measured as part of the Delaware Basin Drilling Survei llance Plan, WP 02-PC.02 (COB-M2009-G). This surveillance program measures and records many parameters related to drilling activities around

the WIPP site. The results of the surveillance program are documented annually in the Delaware Basin Monitoring Annual Report, DOE/WIPP 08-2308 (COB-M2009-M).Page 9 of 17Page 10 of 17 The inspector reviewed the drill ing surveillance database, exam ined drilling rate changes, and permitted and active injection wells while interviewing staff. The inspector reviewed Texas

and New Mexico well database ACCESS files and maps of oil and gas wells around WIPP (Figure 2, Oil and Gas Wells Around WIPP, yellow dot s are oil wells). The inspector verified that DOE tracks and reports the drilling rate and the number of Castile brine encounters near WIPP and reports results annually.

4.5 Monitoring of Subsidence Parameters

DOE committed to measure subsidence at th e WIPP site. This parameter is documented as part of the WIPP Underground and Surface Surveying Program, WP 09-ES.01 (COB-M2009- B). DOE performs subsidence surveys at the site annually during pre-closure operations. The results of this program are reported annually in the WIPP Subsidence Monument Leveling Survey – 2009, DOE/WIPP 09-2293 (COB-M2009-F).

Subsidence staff demonstrated the Office Procedure (Section 2 of WP 09-ES4001: COBM2009-N) to the EPA inspector which describes the steps taken to process raw field survey data

and to calculate final surface el evations published in their annual report (COB-M2009-S62 to - S64). DOE demonstrated that the subsidence parameter is measured and reported yearly.

5.0 Summary of findings, observations, concerns, and recommendations.

Based on program documents, interviews, and field demonstrations during the inspection, the Agency concludes that the monitoring pr ogram covers the ten monitoring parameters required by EPA’s 1998 Certificatio n Decision. This inspection de termined that the monitoring, sample collection, and sample/data analysis procedures were comple te and appropriate; that staff were adequately trained and impl emented the procedures adequately ; and that appropriate quality assurance measures are applied. EPA continue s to find that DOE has maintained adequate parameter monitoring during the past year and ha s the procedures and requirements in place to sustain their program into the next year . EPA has no findings or concerns.Page 11 of 17 

### Attachment A: Inspection Plan and Checklist

WIPP Monitoring Inspection Plan 40 CFR 194.42 for the year 2009

Purpose : Verify that the Department of Energy (DOE) can demonstrate that the Waste Isolation Pilot Plant (WIPP) is monitoring the parameter commitment s made in the documentation to support the EPA’s certification decision, in particular CCA , Volume 1, Section 7.2, Table 7.7 and Appendix MON. This inspection is conducted unde r the authority of 40 CFR 194, Section 21.

This inspection is part of EPA’s continued overs ight to ensure that WIPP can, in fact, monitor the performance of significant parame ters of the disposal system.

Scope: Inspection activities will include an examinati on of monitoring and sampling equipment both on and off site, and in the underground. A revi ew of sampling procedures and measurement techniques may be conducted. Quality assura nce procedures and documentation for each of

these activities will also be reviewed.

Focal Areas of This Year’s Inspection:

- What has changed in the monito ring program this past year?

- What documentation and procedures have changes?

- Update the monitoring program a nd results for the past year.

- Have any monitoring parameters changed, a nd have any action limits been achieved?

Location : This inspection will be held at the WIPP facility location twenty-six miles south east of Carlsbad, New Mexico and the surrounding vicinity as needed.

Duration : The EPA expects to complete its inspection in two days. Each day will begin with an opening meeting at 8:00 a.m. and end befo re 5:00 p.m. with a closeout session.

Expected Date : Week of July 13, 2009.

Documents For Review: Just like past years provide la test versions of any documentation and/or procedures related to your m onitoring program as soon as possible.Page 12 of 17 Monitoring Commitments – July 2009 Geomechanical Parameters

# Question Comment (Object ive Evidence)

SAT = Satisfactory Result

1 Does DOE demonstrate that they have implemented plans/programs/procedures to

measure -

a) Creep Closure;

b) Extent of Deformation;

c) Initiation of Brittle Deformation and

d) Displacement of Deformation Features

during the pre-closure phase of operations as specified in the CCA part of the geomechanical monitoring system?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) WIPP Geotechnical Engineering Program Plan, (WP 07-01: COB-M2009-E), documents plans to measure, report, and the QA requirements related to these activities.

Section 3.0 of WP 07-01 documents the geomechanical monitoring program and

records the activities associated with this program. Section 4.0 of WP 07-01 documents the quality assurance requirements for these activities.

WIPP site staff discussed changes to the program during the past year (COB-M2009- I8). Staff demonstrated the adequacy of the program and that the program produces satisfactory results (COB-M2009-S42 to S47). They showed samples of remote measurements, sample plots, and staff preformed underground manual measurements of convergence (Photos 2009- 07-15_09 Annual Inspection 00105 to 00110, COB-M2009-P1). The inspector toured the underground and reviewed the computer system and databases used to collect and process recorded data.

Results of this program are documented annually in the Geotechnical Analysis Report for each reporting period (DOE/WIPP 09- 3177; COB-M2009-A1 and -A2).

The inspector verified that the geomechanical parameters continued to be appropriately monitored by DOE. SAT

2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1 above? 40 CFR 194.22 During this inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the geotechnical investigations are reported annually? (CCA, App. MON, Page MON-10) WP 07-01, Section 3.2 requires that analysis be performed annually and results are published in the annual geotechnical analysis report (DOE/WIPP 09-3177). SATMonitoring Commitments – July 2009 Hydrological Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have implemented plans/programs/procedures to

measure -

a) Culebra Groundwater Composition;

b) Change in Culebra Groundwater Flow

Direction

during the pre-closure phase of operations as specified in the CCA part of WIPP’s groundwater monitoring plan?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) WIPP Groundwater Monitoring Program Plan, WP 02-1 (COB-M2009-C) documents plans to measure, document, report, and the QA requirements for these activities. WP 02-1

records the activities associated with this program (Section 4), methods used (Sections 4 and 5), data analysis (Section 6) and annual reporting requirements (Section 7.2.2). Section 10.0 of WP 02-1 documents quality assurance requirements.

WIPP site staff discussed changes to the program over the past year (COB-M2009-I3). Staff explained computer code contouring techniques used to develop maps to find flow

direction in the Culebr a and compared results to previous the method (COB-M2009-S15). SNL staff developed a new procedure called, Preparation of Culebra Potentiometer Surface Contour Maps, SP 9-9 (COB-M2009-S12) that standardizes potentiometer surface development. Results are documented annually in the WIPP Annual Site Environmental Report for 2007 (DOE/WIPP 08-2225: COB-A2009-C) Figure 6.11, Appendix E, and Appendix F. SAT

2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1 above? (CCA, App MON, Page MON-22) 40 CFR 194.22 During this inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the groundwater monitoring program are reported annually? (CCA, App. MON, Page MON-22) Results are published annually in the WIPP Annual Site Environmental Report for 2007 (DOE/WIPP 08-2225: COB-A2009-C)

Section 6.0. SATPage 14 of 17 Monitoring Commitments – July 2009 Waste Activity Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have implemented plans/programs/procedures to

measure -

a) Waste Activity?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) WIPP Waste Information System Program andData Management Plan (WP 08-NT.01: COBM2009-H2, Section 6.0) describes how the

WWIS is used to measure and store waste activity information. WWIS User’s manual (DOE/CBFO 97-2273: COB-M2009-O) documents procedures used to gather, store, and process waste activity information

. Table 3 of the Annual Change Report 2007/2008, (DOE/WIPP 08-3317: COB-M2009-P) updates waste activity information annually.

WWIS staff discussed changes during the past year (COB-M2009-I10) and demonstrated the use of the WWIS and generated numerous waste related reports (COB-M2009-W2 toW4). Such as the Nuclide Report (COBM2009-W1) which summaries isotopes emplaced at WIPP. These activities demonstrate that waste activity is adequately

monitored. SAT

2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1? (CCA, App WAP, page C-30) 40 CFR 194.22 During this inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the waste activity parameters are reported annually? (CCA Volume, Section 7.2.4 Reporting) WP 08-NT.01 Section 6, page 13 “Regulatory Reporting” documents that results are reported annually and DOE/WIPP 08-3317 verifies that results are published annually. SATMonitoring Commitments – July 2009 Drilling Related Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have implemented plans/programs/procedures to

measure -

a) Drilling Rate; and

b) Probability of Encountering a Castile Brine

Reservoir?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) The Delaware Basin Drilling Surveillance Plan, (WP 02-PC.02: COB-M2009-G), documents the program to measure, record, report, and the QA requirements for these

activities. Section 7.0 of WP 02-PC.02 documents quality assurance requirements. The Delaware Basin Drilling DatabaseUpgrade Process (WP 02-EC3002: COBM2009-I) documents the process used to update databases with information from

various commercial and state sources. Drilling rate and Castile brine encounter data are reported annually in the Delaware Basin Monitoring Annual Report (DOE/WIPP 08- 2308; COB-M2009-M) in Sections 2.5 and

2.6.

WIPP site staff discussed changes during the past year (COB-M2009-I2). They reported on brine encounters, drilling rate calculations, and provided maps of drilling activities near WIPP (COB-M2009-D2a, D2b). They also provide the latest version of the New Mexico well databases (COB-M2009-D3). They demonstrated that DOE is adequately monitoring these parameters through the Delaware Basin monitoring program. SAT

2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1 above? (CCA, App DMP, page DMP-9) 40 CFR 194.22 During this inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the drilling related parameters are reported annually? (CCA Volume, Section 7.2.4 Reporting; App DMP, page DMP-9) WP 02-PC.02 Section 6.0 documents that results are reported annually. DOE/WIPP 08- 2308 verifies that these parameters are updated and reported annually. SATPage 16 of 17 Monitoring Commitments – July 2009 Subsidence Measurements

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have implemented plans/programs/procedures to

measure -

a) Subsidence measurements?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) WIPP Underground and Surface Surveying Program (WP 09-ES.01: COB-M2009-B), documents the program used to measure, record, document, report (Section 3.3), and the QA requirements (Section 4.0) for these activities. Subsidence Survey Data Acquisition Report technical procedure (WP 09-ES4001: COB-M2009-N) documents the process for acquiring subsidence data (Section 1.0), updating the database (Section 2.0), and publishing the annual subsidence report (Section 2.2). The WIPP Subsidence Monument Leveling Survey - 2008 (DOE/WIPP 09-2293: COB-M2009-F) documents that DOE reports this parameter annually and the results of this program (Section 5.0).

Site staff discussed ch anges to the program during the past year (COB-M2009-I7). Site staff demonstrated that procedures are adequately implemented when they showed how the raw field survey data collected is reduced to useful survey data and how annual results are calculated (COB-M2009-S62 to – S64). They demonstrated that subsidence is adequately monitored at the site. SAT

2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1? 40 CFR 194.22 During this inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the subsidence measurements are reported annually? (CCA Volume, Section 7.2.4 Reporting) WP 09-ES.01 Section 3.3.1 documents that results are reported annually. DOE/WIPP 09- 2293 demonstrates that results are published annually. SAT

### Attachment B: Documents Reviewed